Though these four appeals relate to different assessees, they involve common question. They are, therefore, disposed of by this single order. dispute in these appeals relates to assessee's claim for deduction under s. 4(1)(iv) of WT Act. Both assessees are partners of firm M/s Tangree & Co. which owns house property value whereof is duly reflected in computation of their net wealth. assessees contention before WTO was that their interest in houses property should be computed after deducting exemption provided for by s. 5(1)(iv). This claim was negatived by WTO relying upon decision of Tribunal in case of Shri H. K. Tangree in WTA Nos. 315 to 318 (Cal) of 1978-79 for asst. yrs. 1972-73 to 1975-76. There said conclusion has been confirmed by AAC on appeals filed by assessee. assessees have come up in second appeals before us. We have heard representatives of parties at length in these appeals. question as to how far partner is entitled to deduction under s. 5 i n respect of assets owned by firm in which he is partner is not free from difficulty and there are several conflicting opinions given by various High Courts. For Revenue, we may refer to decision of Madras High Court in Purshottamdas Goculdas vs. CWT 1976 CTR (Mad) 361: (1976) 104 ITR 608 (Mad), where in it was held that assessee could not claim to be entitled to any portion of house property owned by firm of which he was partner as exclusively belonging to him and hence he was not entitled to claim any exemption under s. 5(1) (iv) of Act. Contrary view was taken by Karnataka High Court in CWT vs. Mrs. Christine Cardoza (1978) 114 ITR 532 (Kar), wherein agricultural land was owned by partnership firm and is computing net wealth of partners they were held entitled to claim deduction in respect of value of this land under s. 5(1)(iv) of WT Act. Of course, there are some other decisions on subject which deal with question of deduction admissible to firm in first instance and another deduction which might be again claimed by partners. We need not refer to them at length. There are also conflicting decisions arrived at by Tribunal. In L. Gulabchand Jhabakh vs. WTO (1982) 14 TTJ (Mad) 465 (SB): 1 SOT 613 (Mad) (SB) in WTA Nos. 372 & 373 (Mad) of 1979, two assessees were partners in firm owning agricultural land. It was held by Special Bench of Tribunal that both of them were entitled to separate exemption of Rs. 1,50,000 in computation of their net wealth. As against this, we may refer to decisions of D-Bench and B- Bench of Tribunal in case of these very assessees in WTA Nos. 315 to 318 (Cal) of 1978-79 and WTA Nos. 26 to 29 (Cal) of 1980 wherein it has been held that none of partners is entitled to any deduction at all. We are, therefore, posed with very difficult question and to find appropriate answer to same. We went through entire history of legislation and authorities on subject. After carefully considering all relevant provisions we are of opinion that while deciding question of deduction firm itself should be considered to be assessee and in first instance net wealth of firm has to be computed after granting such deductions as may be admissible to individual assessee. Our conclusion is based upon clear language used by framers of WT Act. assessee's interest in partnership firm might have been includible in his net wealth or it may not have been. Fortunately framers of WT Act have not only given guidance regarding its inclusion but they have also laid down procedure of computing same. According to cl. (b) of s.4(1) of WT Act where assessee is partner in firm or member of AOP (not being Cooperative Housing Society value of his interest in firm or AOP to be included in his net wealth is to be determined in prescribed manner. According to cl.(n) of s.2 "prescribed" means prescribed by rules under this Act. Now r. 2 along with rr. 2A to 2-I are relevant rules in this behalf. According to r. 2(1) value of interest of person in firm of which he is partner of AOP of which he is member shall be determined 8in manner provided therein. net wealth of firm or Association on valuation date has first to be determined. Now, according to sub-s. (1) s. 5, wealth- tax is not payable by assessee in respect of certain assets and such assets shall not be included in net wealth of assessee. According to cl.(m) of s. 2 net wealth means amount of aggregate value of assets belonging to assessee on valuation date computed in accordance with provision of this Act. proper appreciation s of these provisions contained in WT Act and rules would leads us to one and to only one conclusion i.e., net wealth of firm has to be computed after giving necessary exemptions to firm itself as if it was assessee. In this behalf we may point out that if intention of framers of Act was not to give any exemption they could have simply computed value of partner's interest in firm according to amount of capital standing at his credit but this is what they have not done. Instead thereof they have laid down detailed procedure to determine value of interest of person in firm of which he is partner or AOP of which he is member. In subsequent part of this rule they have referred to assets which are disclosed in balance sheet and those which are not. Then they have referred to certain liabilities and discussed question of their inclusion. According to cl.(c) of r. 2D value of any asset in respect of which wealth-tax is not payable even if it is disclosed in balance sheet is not to be taken into account for purpose of r. 2A. This means that even when WTO proceeds to determine net value of assets of business as whole having regard to balance sheet of such business under r. 2A still value of exempted assets would be excluded. important thing to note in this behalf is that it is not capital invested by partner that would determine value of his interest. It is total assets of firm computed in particular manner on which value of interest of partner to be included in its net wealth would depend. So far as decision of Calcutta Benches of Tribunal are concerned they proceed on basis of decision of Calcutta High Court i n Sarvamangala Properties Ltd. vs. CIT (1973) 90 ITR 267 (Cal). What had been held therein only was that under Indian Partnership Act firm is entity known to law and capable of acquiring and owning property both movable and immovable. Under Indian IT Act, 1922, firm has same definition as in Partnership Act and by owning property would be liable to tax. Impliedly i t holds that partners would not be considered to be owners of property owned by firm. But this is not actual position under WT Act. No firm is liable to wealth-tax as charging of s. 3 of Act would show. Only individuals and HUFs are liable to pay taxes on their wealth out firms are not. Only interest of individuals whereas partners in firms are to be included in computation of their wealth and that too has to be done in particular manner. If Calcutta High Court decision was applicable to Wealth- tax then no inclusion of share of assets of partner in firm could be made in computation of his net wealth. This is, however, not what has been done by WTO or Tribunal earlier. In this behalf we are supported by decision of Patna High Court in CWT, Bihar vs. Nandlal Jalan (1980) 14 CTR (Pat) 181:(1980) 122 ITR 781 (Pat). Although decision is not quite clear, both conflicting authorities on subject i.e., Purshottamdas Goculdas vs. CWT (supra) and CWT vs. Christine Cardon (supra) have been considered and exemption was allowed. Still later matter has been considered at full length by Andhra Pradesh High Court in CWT vs. Narendra Ranjelker (1981) 129 ITR 203 (AP) wherein their Lordships have thoroughly considered in relevant provisions on same lines as we have discussed above. They have ultimately come to conclusion that in computing at net wealth of firm ordinary deductions available to individual have to be allowed but thereafter no further deduction is to be allowed in hands of individual partners. Their Lordships have considered pros and cons of all contrary argument advanced in case. Before departing we may also refer to contrary argument that can be possibly advanced on behalf of assessees that they should be granted separate exemptions in respect of their share of assets owned by firm in which they are partners. As we have pointed out above, there is no provision for grant of separate exemptions under cl.(b) of s. 4(i) of WT Act. Secondly where intention of framers of WT Act was to grant separate exemption in respect of value of assets forming part of industrial undertaking belonging to firm or AOP of which assessee is partner or member, specific provision in form of cl. (xxxii) has been incorporated in s. 5(1) of WT Act. Form perusal of same it would follow that in respect of these exemptions each of partners of firm or members of AOP can claim maximum deduction admissible under s. 5(1A) of WT Act but in respect of assets other than those forming part of industrial undertaking ordinary exemption under s. 5(1)(iv) will not be available to assessee apart from what may be available to firm otherwise because there is not apart from what may be available to firm otherwise because there is not provision under cl.(iv) of s. 5(1) corresponding to one which is there in cl. (xxxii) immediately following cl.(xxxi) thereof. For reasons given above, we accept appeals to extent that interest of assessees in firms of which they are partners shall be computed in manner prescribed by rules under WT Act which we have thoroughly discussed above. appeals are partly allowed as above. *** K. K. TANGREE v. WEALTH-TAX OFFICER